“… and then AB 72 happened …”

by

Chamberlin, Keith, MD, MBA, FASA

| Oct 09, 2017

CSA recently held its inaugural Practice Management Committee meeting. Often overshadowed by legislative, regulatory and political priorities … practice management issues will now get undivided attention from this newly created, stand-alone committee that is part of CSA’s Legislative and Practice Affairs Division. At the inaugural meeting several committee priorities were discussed based on feedback from the recent CSA practice management survey … “and then AB 72 happened!”

AB 72 implementation will remain a major focus of the committee for the next 12 months as regulations are developed and implemented by the California Department of Managed Health Care (DMHC) and the California Department of Insurance (CDI).

CSA has been updating members on what these changes will mean for anesthesia practices and groups. Click here for a summary of AB 72 implementation and what you need to know. CSA leaders, legal counsel and lobbyists have been feverishly providing input to DMHC and CDI, in coordination with CMA and other hospital-based specialties, CEP America and a handful of large anesthesia groups. Both departments needed an in-depth “anesthesia residency training” in the unique billing and reimbursement methodology challenges. For example, health plans and insurers need to submit specific contract information for anesthesia services to both DMHC and CDI in order to determine the average contact rate (ACR) prescribed in AB 72. Until CSA engaged, both departments were not even aware that all anesthesia contracts include an anesthesia conversion factor expressed in dollars per unit. This is just one of many critical anesthesia nuances that CSA has been helping the regulators understand. Click here for the CSA recent written comments to DMHC [insert hyperlink to our letter].

In order to keep CSA members apprised of the AB 72 regulatory implementation activities undertaken by CSA, and to provide easy access to the many different links and resources provided by CDI and DMHC, we are launching a dedicated AB 72 information and resource page on the CSA website. This webpage will include updates on what CSA is doing, what you can do, and important timelines and resources for AB 72 implementation.

You will also notice an increased communications presence from CSA as both the DMHC and CDI are set to launch regulations before year-end to further implement AB 72. Tantamount to these forthcoming regulations is how the ACR will be determined beginning on January 1, 2019.

CSA needs to hear examples of specific contracting problems from members and large groups as it relates to AB 72. As CSA suspected, many anesthesiologists and anesthesiology groups have experienced predatory contracting issues with health plans and insurers as a result of AB 72. We also want to make sure that health plans and insurers are complying with the interim payment and Independent Dispute Resolution Process (IDRP) provisions of AB 72, which respectively took effect on July 1, 2017 and September 1, 2017.